Case 1:15-cv-07433-RWS Document 590 Filed 02/02/17 Page 1 of 3

United States District Court

Southern District of New York
Virginia L. Giuffre,

Plaintiff, Case No.: 15-cv-07433-RWS

v.

Ghislaine Maxwell,

Defendant.

____________________________/

DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF

PLAINTIFFS RESPONSE IN OPPOSITION TO MOTION TO INTERVENE

I, Sigrid McCawley, declare that the below is true and correct to the best of my

knowledge as follows:

1. I am a Partner with the law firm of Boies, Schiller & Flexner LLP and duly

licensed to practice in Florida and before this Court pursuant to this Courts Order granting my

Application to Appear Pro Hac Vice.

2. I respectfully submit this Declaration in Support of Plaintiffs Response In

Opposition to Motion to Intervene (DE 550).

3. Attached hereto as Exhibit 1 is a true and correct copy of January 6, 2015,

Australian Broadcasting Systems Article.

4. Attached hereto as Exhibit 2 is a true and correct copy of January 22, 2015, Local

10 News.

1
 Case 1:15-cv-07433-RWS Document 590 Filed 02/02/17 Page 2 of 3

I declare under penalty of perjury that the foregoing is true and correct.

/s/ Sigrid McCawley______________

Sigrid McCawley, Esq.

Dated: February 2, 2017.

Respectfully Submitted,

BOIES, SCHILLER & FLEXNER LLP

By: /s/ Sigrid McCawley

Sigrid McCawley (Pro Hac Vice)
Meredith Schultz (Pro Hac Vice)
Boies Schiller & Flexner LLP
401 E. Las Olas Blvd., Suite 1200
Ft. Lauderdale, FL 33301
(954) 356-0011

David Boies
Boies Schiller & Flexner LLP
333 Main Street
Armonk, NY 10504

Bradley J. Edwards (Pro Hac Vice)

FARMER, JAFFE, WEISSING,
EDWARDS, FISTOS & LEHRMAN, P.L.
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
(954) 524-2820

Paul G. Cassell (Pro Hac Vice)

S.J. Quinney College of Law
University of Utah
383 University St.
Salt Lake City, UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.

2
 Case 1:15-cv-07433-RWS Document 590 Filed 02/02/17 Page 3 of 3

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 2nd day of February, 2017, I electronically filed the

foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the

foregoing document is being served to all parties of record via transmission of the Electronic

Court Filing System generated by CM/ECF.

Laura A. Menninger, Esq.

Jeffrey Pagliuca, Esq.
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Tel: (303) 831-7364
Fax: (303) 832-2628
Email: lmenninger@hmflaw.com
jpagliuca@hmflaw.com

/s/ Sigrid McCawley

Sigrid McCawley

3
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EXHIBIT 1
 Case 1:15-cv-07433-RWS Document 590-1 Filed 02/02/17 Page 2 of 4

SHOW: AUSTRALIAN BROADCASTING SYSTEM (ABC) 7.30 8:05 PM AEST ABC

January 6, 2015 Tuesday

LENGTH: 942 words

HEADLINE: Prince Andrew under pressure as Palace disputes teen sex scandal
claims

REPORTERS: Philip Williams

BODY:

LEIGH SALES, PRESENTER: It's been a few years since Britain's Royal Family has
been embroiled in a serious scandal, but once again, Prince Andrew has stepped
forward.

He's accused of having sex with an underage girl in sensational details aired in an
American court case.

The young woman says she was forced to entertain the Duke at the behest of his
friend, billionaire and convicted paedophile Jeffrey Epstein.

Prince Andrew's ex-wife, Sarah Ferguson, has leapt to his defence and Buckingham
Palace is also strenuously denying the allegations.

But, as Europe correspondent Philip Williams reports, the claims have blown apart
the always uneasy calm between the Palace and the British press.

PHILIP WILLIAMS, REPORTER: As fifth in line to the throne, whatever Prince Andrew
does or says will never go unnoticed.

So when media reports about a lawsuit in the US emerged linking his name with
underage sex, the long period of relative Royal calm was abruptly shattered.

This woman, Virginia Roberts, is believed to be the person named in court papers as
"Jane Doe 3". In a newspaper interview she claims she was used for underage sex by
American billionaire Jeffrey Epstein and says she was lent out to his rich and
powerful friends, including Prince Andrew. It's claimed she had sex with him three
times when she was 17 at Jeffrey Epstein's luxury Caribbean Island home and in New
York and London, all denied by Prince Andrew.

VICTORIA MURPHY, UK MIRROR ROYAL CORRESPONDENT: If this doesn't go away

quickly, if these allegations continue to be made, if more allegations are added, this
could be incredibly damaging, not just for Andrew, but for the monarchy as a whole.

PHILIP WILLIAMS: It all seems a world away from the golden glow of recent Royal
events - a wedding that cemented the popularity of Prince William and his bride.
Followed of course by the arrival of baby Prince George. And for the Queen, a
diamond jubilee, a celebration of 60 years on the throne, reason for her to smile as
the nation and beyond said thanks for her never-ending job.
 Case 1:15-cv-07433-RWS Document 590-1 Filed 02/02/17 Page 3 of 4

Over the weekend, that run of feel-good luck expired.

Normally with a story like this, Buckingham Palace would be more inclined to stay
quiet, not to give any oxygen whatsoever to the sort of claims that have been made.
But this time, it's very, very different. Not one, but two statements saying Prince
Andrew is completely innocent of all the accusations.

VICTORIA MURPHY: They issued one statement initially in response to the allegations
that Prince Andrew had had sex with an underage minor and that was what they
were responding to and they were categorically denying that that had been the case.
However, in doing that they had left the door open that perhaps he was only denying
the fact that she was a minor and questions were being asked about that. So when
more of her allegations surfaced, they decided that they needed to release an even
stronger denial, categorically denying any sexual contact whatsoever.

PHILIP WILLIAMS: What isn't in dispute is that Prince Andrew and Jeffrey Epstein
were good friends over a number of years.

In 2008, Mr Epstein was sentenced to 18 months' jail for soliciting an underage girl
for the purposes of prostitution. That, after a controversial plea bargain. He remains
a registered sex offender.

Yet in 2011, after his release, Prince Andrew was seen with his old friend in New
York Central Park. That cost Prince Andrew an unpaid job he was said to have loved
as the UK's Trade and Industry special representative, opening doors for British
business overseas.

CHRIS BRYANT, LABOUR MP (March, 2011): But I'm afraid he's now just become a
national embarrassment. And my worry is that sometimes when he goes on these
trips, I'm not sure whether he's helping us out or he's just helping himself.

PHILIP WILLIAMS: For him, that door closed as a direct result of his association with
Jeffrey Epstein.

VICTORIA MURPHY: People who know Prince Andrew have said that he is very loyal
to his friends and that that is one of his strong points. However, I think that those
closest to him now accept that that particular friendship and the loyalty to Jeffrey
Epstein that continued until after he was convicted of paedophilia, I think people are
now saying, you know, he accepts that that was a mistake. However, what is being
said is that Andrew is only guilty of choosing his friends badly. He's not guilty of
anything else.

PHILIP WILLIAMS: Prince Andrew isn't the only one named in the court documents,
and while he isn't publicly defending himself, another of those accused certainly is.

Harvard Law Professor Alan Dershowitz has been doing the media rounds of the US
and beyond. He denies even knowing his accuser, let alone having sex with her.

ALAN DERSHOWITZ, HARVARD LAW SCHOOL: My goal is to bring charges against

the client and require her to speak in court. She - if she believes she has been hurt
by me and by Prince Andrew, she should be suing us for damages. I welcome that
lawsuit. I welcome any opportunity which would put her under oath and require her
to state under oath these false allegations.
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PHILIP WILLIAMS: Under the plea bargain struck with prosecutors by Jeffrey Epstein,
it appears that other potential allegations may not end up tested in court and that
could apply to possible co-conspirators, an arrangement alleged victims were not
involved with.

Through Palace statements, the Duke of York has unequivocally denied any
wrongdoing. He's not charged with anything, nor has he been questioned by police.

But the Queen's second son is in a spotlight he cannot wish away. His annus
horribilis may have just begun.

LEIGH SALES: Philip Williams reporting from London.

LOAD-DATE: January 7, 2015

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EXHIBIT 2
 Case 1:15-cv-07433-RWS
Alan Dershowitz: Document
'Sex slave' accuser is serial 590-2| News
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Alan Dershowitz: 'Sex slave' accuser is serial liar, prostitute

Famed attorney slams woman who claims he had underaged sex with her
Author: Bob Norman, Reporter, bnorman@Local10.com
Published On: Jan 22 2015 06:03:14 PM EST Updated On: Jan 22 2015 06:20:00 PM EST

PEMBROKE PARK, Fla. -

Well-known attorney and Miami Beach resident Alan Dershowitz emphatically denied allegations made in
newly-filed court papers that he had sex six times with an underage girl who at the time was serving
as a "sex slave" for wealthy financier -- and convicted sex offender -- Jeffrey Epstein.

Related: Billionaire's 'sex slave' details allegations against Prince Andrew, Dershowitz

"This is a woman who is a serial liar," Dershowitz told Local 10 News reporter Bob Norman. "She's lied, lied,
lied, lied."

"But she wasn't lying about being sexually abused by Jeffrey Epstein," said Norman.

"That is a different issue," said Dershowitz. "That is between her and Jeffrey Epstein."

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The woman is Virginia Roberts, one of as many as 40 women who allege that Epstein recruited them while
they were minors into a sex ring based at Epstein's Palm Beach mansion.

Roberts alleges in a 14-page affidavit -- which included newly-released photos she said were taken by Epstein
when she was 15 -- that Epstein groomed her as "sex slave" to gratify not only him but his powerful friends.

She wrote that she was introduced to Epstein at the mansion by heiress Ghislaine Maxwell, the daughter of the
late British publisher Robert Maxwell, on the pretext that she would be paid to give him a "massage," which she
wrote was Epstein's "code word for sexual encounters."

"From the first time I was taken to Epstein's mansion that day, his motivations and actions were sexual, as were
Maxwell's," Roberts writes in the affidavit. "My father was not allowed inside. I was brought up some stairs.
There was a naked guy, Epstein, on the table in the room. Epstein and Maxwell forced me into sexual activity
with Epstein ... I was paid $200."

She wrote that she then began working for Epstein, and traveling around the country and world with him.

"Jeffrey Epstein and Ghislaine Maxwell trained me to do what they wanted, including sexual activities and the
use of sexual toys," she wrote. "The training was in New York and Florida at Epstein's mansions. It was
basically every day and was like going to school ... I was trained to be 'Everything a man wanted me to be.' It
wasn't just sexual training -- they wanted me to be able to cater to all the needs of the men they were going to
send to me."

In the affidavit, she alleges that Dershowitz was one of those men and that she had sex with him six times
beginning when she was 16 at Epstein's residences, as well as on his jet and private island. She also added
details about her allegations that Epstein -- who served 13 months in jail after being convicted of soliciting a
minor for sex in 2008 -- ordered her to have sex on three occasions with Prince Andrew in London at the age of
17, paying her $15,000 after the first instance.

Read the entire 14-page affidavit here.

Dershowitz said Roberts was a prostitute and questioned whether she is now, at the age of 31, a fit mother for
her three children.

"She's now an admitted prostitute," said Dershowitz. "I can tell you she is still a prostitute: she is selling these
false stories now for money about me. That is a form of prostitution."

"Do you have any concern calling her a prostitute when she was victimized at such an early age by a wealthy
man?" Norman asked.

"She was not victimized ... she made her own decisions in life," said Dershowitz.

"But at the age of 15 some would say ... she was taken advantage of," said Norman.

"I'm talking about the age of 19," said Dershowitz.

"But it started when she was 15," said Norman.

"I am not involved in that," he said. "I have no knowledge of that. That's between her, and the federal
government and the people who victimized her. All I know is she has victimized me. At the age of 31 she has
made up false allegations against me. She is a mother of three children, and she is now living a lie to her three
children and the question is whether she is an adequate mother of her three children going around selling her
false stories of prostitution."

Dershowitz is an admitted long-time friend of Epstein's who frequented his homes at the time Roberts and
other young girls were in Epstein's employ. But he insisted he never saw an underage girl in Epstein's company.
A former Epstein employee, the late Alfredo Rodriguez, testified under oath that Dershowitz was at the Palm
Beach mansion at the same time underage girls were at the home.

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"That's not true," said Dershowitz. "I was never in Jeffrey Epstein's house or any of the houses in the presence
of any young woman. Now were there other young women in other parts of the house giving massages when I
wasn't around? I have no idea of that. I can only say I never saw a young underage woman. If I had I would
have left the house and never come back, period."

He told Norman that he had one massage at Epstein's home and it was with an adult woman.

"I kept my underwear on during the massage," he said. "I don't like massages particularly."

One of the more salacious allegations made by Roberts is that Dershowitz "was so comfortable with the sex that
was going on that he would even come and chat with Epstein while I was giving oral sex to Epstein." Dershowitz
called that allegation absurd.

"Alan Dershowitz was standing there and talking about what? The weather, the stock market? It's the most
preposterous thing imaginable," said Dershowitz.

Dershowitz, who has issued a denial to Roberts' basic claims in a sworn affidavit of his own, said he would
willingly be deposed on the matter. Roberts' attorneys have claimed that Dershowitz has refused to submit to
deposition.

When questioned about it, Dershowitz said he would be deposed in the case, but only after Roberts and her two
lawyers are deposed. The lawyers have sued Dershowitz for defamation after he alleged they should be
disbarred for initially putting Roberts' allegations in court papers.

"I am happy today to express my willingness to be deposed after the three of them are deposed," he said. "That's
the order it should occur because they are the accusers. I am the one who is defending myself against their
accusations."

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